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XAVIER BECERRA Attorney General of California MATTHEWM. DAVIS Supervising Deputy Attorney General MARTIN W. HAGAN Deputy Attorney General State Bar No. 155553 600 West Broadway, Suite 1800 San Diego, CA 92101 P.O. Box 85266 San Diego, CA 92186-5266

Telephone: (619) 738-9405 Facsimile: (619) 645-2061

Attorneys for Complainant

FILED STATE OF CALIFORNIA

MEDICAL BOARD OF CALIFORNIA

SA~AM!TO:~I 20.1\_ BY .c: .p ~ \ NAL YST

BEFORE THE MEDICAL BOARD OF CALIFORNIA

DEPARTMENT OF CONSUMER AFFAIRS STATE OF CALIFORNIA

In the Matter of the Accusation/Petition to Revoke Probation Against:

Mark Anthony Knight, M~D. 17731 Irvine Blvd., Suite 101 Tustin, CA 92780-3235

Physician's and Surgeon's Certificate

Case No. 800-2019-056493

ACCUSATION AND PETITION TO REVOKE PROBATION

17 No. A78828,

18 Respondent.

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20 Complainant alleges:

21 PARTIES

22 1. Kimberly Kirchmeyer (Complainant) brings this Accusation and Petition to Revoke

23 Probation solely in her official capacity as the Executive Director oqhe Medical Board of

24 California, Department of Consumer Affairs (Board).

25 2. On or about April 24, 2002, the Medical Board issued Physician's and Surgeon's

26 Certificate Number A 78828 to Mark Anthony Knight, M.D. (Respondent). The Physician's and

27 Surgeon's Certificate was in full force and effect at all times relevant to the charges brought

28 herein and will expire on October 31, 2020, unless renewed.

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ACCUSATION AND PETITION TO REVOKE PROBATION NO. 800-2019-056493

1 JURISDICTION

2 3. This Accusation and Petition to Revoke Probation is brought before the Board, under

3 the authority of the following laws and the prior disciplinary action entitled In the Matter of the

4 Petition for Reinstatement of Mark Anthony Knight, MD. before the Medical Board of California,

5 in Case Number 800-2014-002269. All section references are to the Business and Professions

6 Code (Code) unless otherwise indicated.

7 4. In the prior disciplinary action entitled In the Matter of the Accusation Against Mark

8 Anthony Knight, MD. before the Medical Board of California, in Case Number 06-2008-190093,

9 Respondent surrendered his medical license effective December 15, 2010, with an Accusation

10 pending against him concerning allegations of professional misconduct. On January 8, 2014,

11 Respondent filed a Petition for Reinstatement of his medical license that was granted on February

12 6, 2015, with an effective date of March 6, 2015. As a result of the Petition for Reinstatement

13 being granted, Respondent's license was reinstated and then immediately revoked, with said

14 revocation being stayed, and Respondent being placed on probation for a period of five years

15 from the effective date of March 6, 2015, under various terms and conditions. That decision is

16 now final and is illcorporated by reference as if fully set forth herein

17 · 5. Section 2227 of the Code states:

18 "(a) A licensee whose matter has been heard by an administrative law judge of

19 the Medical Quality Hearing Panel as designated in Section 113 71 of the Government

20 Code, or whose default has been entered, and who is found guilty, or who has entered

21 into a stipulation for disciplinary action with the board, may, in accordance with the

22 provisions of this chapter:

23 "(1) Have his or her license revoked upon order of the board.

24 "(2) Have his or her right to practice suspended for a period not to exceed one

25 year upon order of the board.

26 "(3) Be placed on probation and be required to pay the costs of probation

27 monitoring upon order of the board.

28 "(4) Be publicly reprimanded by the board. The public reprimand may include a

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ACCUSATION AND PETITION TO REVOKE PROBATION NO. 800-2019-056493

I requirement that the licensee complete relevant educational courses approved by the

2 board.

3 "(5) Have any other action taken in relation to discipline as part of an order of

4 probation, as the board or an administrative law judge may deem proper.

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6.

" "

STATUTORY PROVISIONS

Section 2234 of the Code, states:

"The board shall take action against any licensee who is charged with

unprofessional conduct. In addition to other provisions of this article,

unprofessional conduct includes, but is not limited to, the following:

"(a) Violating or attempting to violate, directly or indirectly, assisting in or

abetting the violation of, or conspiring to violate any provision of this chapter.

"(b) Gross negligence.

"(c) Repeated negligent acts. To be repeated, there must be two or more

negligent acts or omissions. An initial negligent act or omission followed by a

separate and distinct departure from the applicable standard of care shall constitute

repeated negligent acts.

"(1) An initial negligent diagnosis followed by an act or omission medically

appropri~te for that negligent diagnosis of the patient shall constitute a single

negligent act.

"(2) When the standard of care requires a change in the diagnosis, act, or

omission that constitutes the negligent act described in paragraph (1 ), including, but

not limited to, a reevaluation of the diagnosis or a change in treatment, and the

licensee's conduct departs from the applicable standard of care, each departure

constitutes a separate and distinct breach of the standard of care.

"

"(f) Any action or conduct which would have warranted the denial of a

certificate.

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ACCUSATION AND PETITION TO REVOKE PROBATION NO. 800-2019-056493

1 7. Unprofessional conduct under Business and Professions Code section 2234 is

2 conduct which breaches the rules or ethical code of the medical profession, or

3 conduct which is unbecoming a member in good standing of the medical

4 profession, and which demonstrates an unfitness to practice medicine. (Shea v.

5 Board of Medical Examiners (1978) 81Cal.App.3d564, 575.)

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7 8.

" "

Section 2266 of the Code states:

8 "The failure of a physician and surgeon to maintain adequate and accurate

9 records relating to the provision of services to their patients constitutes

1 O unprofessional conduct."

11 FIRST CAUSE FOR DISCIPLINE

12 (Gross Negligence)

13 9. Respondent is subject to disciplinary action under sections 2227 and 2234, as defined

14 by section 2234, subdivision (b), of the Code, in that Respondent committed gross negligence in

15 his care and treatment of Patient A 1, as more particularly alleged hereinafter:

16 10. On or about November 27, 2017, patient A, a then-34-year old male, presented to

17 Respondent for liposuction surgery to remove excess fat around his midsection and submental

18 (under the chin) region. According to Respondent's procedure note for the liposuction surgery,

19 Respondent performed suction assisted lipectomy (liposuction surgery), under general anesthesia

20 in an outpatient setting, to patient A's bilateral upper abdomen, bilateral lower abdomen, bilateral

21 flanks, bilateral lower back, and the submental area. According to the procedure note,

22 approximately 3,000 cc's of tumescent fluid was infiltrated with approximately 5,000 cc's of

23 tumescent fluid and fat being aspirated. Following the procedure, patient A was dressed with

24 abdominal pads, taken to the recovery room, and was subsequently discharged. Patient A's

25 discharge instructions included, among other things, instructions to take one to two tablets of

26 Norco every 4 to 6 hours as needed for pain, avoid heavy lifting and strenuous exercise, return to

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28 1 Patient A is being used in place of the patient's name or initials to maintain patient

confidentiality. Respondent is aware of the identity of the patient referred to herein.

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ACCUSATION AND PETITION TO REVOKE PROBATION NO. 800-2019-056493

clinic for follow up in one week and contact Respondent if any unusual or unexpected post-

2 operative events.

3 11. On or about November 29 or 30, 2017, patient A was not feeling well. According to

4 patient A's fiance, she called Respondent to express concern over patient A's symptoms which

5 included, among other things, severe stomach pain, an "over inflated" stomach, a foul smell

6 coming from his navel area, and a rash and bumps on his stomach. Respondent told patient A to

7 come into his office to be evaluated, which he did. Respondent examined patient A and informed

8 him his incisions looked fine and the symptoms he was experiencing were part of the recovery

9 process. Respondent did not order any imaging or request any laboratory studies. Respondent

10 had no documentation of this post-operative visit and could not produce any other documents

11 which should have been included as part of patient A's medical records.2

12 12. On or about November 30 or December 1, 2017, patient A's fiance called Respondent

13 to report patient A was still not doing well. Respondent assured her that everything was fine and

14 told her that if patient A's condition got worse she should consider taking him to the Emergency

15 Department.

16 13. On or about December 2, 2017, patient A was taken to the Emergency Department.at

17 Chino Valley Medical Center (CVMC) in the morning for increasing abdominal pain and

18 subsequent shortness of breath. On admission, patient A complained of diffuse abdominal pain,

19 no bowel movement since the liposuction surgery, inability to tolerate food, weakness, dizziness

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2 The Department of Consumer Affairs, Division of Investigation, Health Quality Enforcement Unit (HQIU) requested any and all of patient A's medical records from Respondent pursuant to an Authorization for Release of Medical Information signed by patient A. In response, Respondent produced eight (8) pages of medical records and indicated, in pertinent part, "I am responding to your request for records relating to this patient. The surgery center at which the procedure was performed was abruptly closed in December of 2017. I have not been there since. I have contacted the owner, [name omitted]. And requested the chart on multiple occasions. I have been told that the chart is not available. I don't know what has happened to this or any of the other charts from this facility ... The only documents available in my possession are the photographs that I took and a copy of the operative report that you will fi~d attached." Respondent admitted at his subject interview with an HQIU investigator that "there are a lot of items" missing from the records including, but not limited to, nursing notes, the anesthesia records, certain legal forms, and preoperative instructions. Respondent informed the HQIU investigator "I just gave you what I have access to, the photographs ... [and] the operative note ... " (Respondent's Interview Transcript, at p. 23.)

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ACCUSATION AND PETITION TO REVOKE PROBATION NO. 800-2019-056493

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and nausea. A CT with contrast was taken of the abdomen and pelvis and reported on December

2 at 8:20 a.m.3 The initial lab results indicated, among other things, a white blood cell count

(WBC) of9.0 K/mm3• After work-up in the Emergency Department, patient A was transferred to

the Intensive Care Unit (ICU) for stabilization and closer observation. On December 2, Dr. H.O.,

the on-call and consulting surgeon, called Respondent to discuss patient A's condition, with

Respondent eventually coming to CVMC to check on patient A, with the encounters documented

as follows:

"ASSESSMENT AND PLAN: Status post liposuction. I am quite concerned about necrotizing fascitis [sic] 4; however, I do not deal with patients status post liposuction. Therefore, we made a call over to Dr. Mark Knight, who did answer the phone with the resident next to me. We did explain to him the lab values as well as CT findings. Dr. Mark Knight reported these are all normal findings for status post liposuction. He believes that the patient was on too much narcotics and that is why his bowels are starting to not move, perhaps leading to his ileus and a narcotic bowel and causing him to have the vomiting. We explained to him the gas.findings. He said that is all normal since he has used air to insufflate the abdomen in order to [get] fat out. Secondly, we offered to transfer the patient to a facility that he has privileges at and he declined saying that the patient is going to simply follow up in his clinic.

"Status post liposuction. Again, I am not familiar with Plastic Surgery postops. We are going to watch him in the ICU, give him IV fluids, resuscitate him, put catheter to get accurate findings and every 6 hours labs and abdominal exams and see how he does. Hopefully, he does improve." (Consultation Report dated December 2, 2017.)

The attending resident documented the following:

"Plastic surgeon, Dr. Mark Knight; was contacted, briefed, regarding patient's history/imaging/vitals/labs. Concern regarding patient's clinical condition by Chino's

3 The CT was reported as follows, in pertinent part, "PERITONEUM, RETROPERITONEUM: No free air. There is extensive subcutaneous fat stranding and gas seen throughout the subcutaneous tissues of the anterolateral abdominal walls. There is a 22.2 x 5.1 x 19 .2 cm complex gas-containing fluid collection within the subcutaneous tissues of the left lateral hemiabdomen .. .IMPRESSION: (1) Extensive subcutaneous fat stranding in gas seen throughout the anterolateral abdominal walls consistent with abdominoplasty changes. A 22-cm complex gas-containing collection within the subcutaneous tissues at the left lateral abdomen wall may represent a gas containing hematoma related to liposuction changes. However, superimposed infection not excluded; (2) Multiple dilated loops of fluid-filled small bowel within the right hemiabdomen without discrete transition point. Notably, the duodenum does not appear to cross expected region of the ligament of Treitz. Small bowel obstruction related to malrotation not excluded. Alternatively, this may reflect postoperative ileus; (3) Small bowel and pelvic ascites; [and] (4) Mild bibasilar atelectasis .... "

4 Necrotizing fasciitis, commonly referred to as the flesh-eating disease, is an acute disease of sudden onset in which inflammation of the fasciae (soft tissue) of muscles or other organs spreads rapidly and results in rapid destruction of overlying soft tissues. Symptoms can include red or purple skin in the affected area, severe pain, fever, and vomiting. Necrotizing fasciitis is typically treated with surgery to remove the affected tissue and intravenous antibiotics.

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ACCUSATION AND PETITION TO REVOKE PROBATION NO. 800-2019-056493

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on call surgeon, Dr. [H.O.], was also expressed. Transfer was offered, but Dr. Knight denied transfer and reported that patient was experiencing a normal procedural outcome. Dr. Knight came to CVMC to assess patient, with the patient's consent. He again reported there was no need to transfer patient. [fl Consult general surgery, Dr. [H.O.]; recommended transfer to hospital where plastic surgeon who performed liposuction procedure has privileges, due to patient's condition." (CVMC History and Physical with service date and time of December 2, 2017, 2:21 p.m.)

5 During this time, Respondent did not have privileges at any hospital. While at CVMC,

6 there were consultations with various specialists including, general surgery, infectious disease,

7 and pulmonology based on the assessments concerning patient A's condition which included, but

8 were not limited to, acute hypoxemic respiratory failure, sepsis, septicemia, possible abdominal

9 wall infection, left shift with leukocytosis, possible abdominal wall hematoma versus abscess and

10 possible necrotizing fasciitis. The general plan for patient A's treatment included, but was not

11 limited to, aggressive support measures, stabilization of patient A's condition, and possible

12 exploratory surgery. On December 3, Dr. H.O., documented that patient A "does feel somewhat

13 better," he had a bowel movement after an enema, and his WBC was within normal limits. On

14 December 4, patient A's condition declined with him having persistent hiccups, voiding dark

15 amber colored urine, his abdomen was firm and distended, and discharge was noted through his

16 umbilicus. The lab results of December 4 indicated an elevated WBC of 14.8 K/mm3, which was

17 outside of normal limits. A CT without contrast was ordered of the abdomen and pelvis and

18 reported on December 4 at 3 :04 p.m. 5 Around this time, the decision was made tci transfer patient

19 A, whose condition on discharge was listed as "guarded," to St. Joseph's Hospital (St. Joseph's)

20 for further care. Patient A was transferred to St. Joseph's on December 4 at approximately 10:00

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5 The CT was reported as follows, in pertinent part, "FINDING: Previously noted extensive subcutaneous inflammation in the anterolateral wall is again noted, with previously seen subcutaneous emphysema mostly replaced by fluid collection. Persistent bibasilar dependent atelectasis within noted. There is decreasing gastric distention with unchanged dilated proximal small bowel loops in the right hemiabdomen and nonvisualization of duodenum extending beyond ligament ofTreitz, unchanged compare [to] prior study. Previously noted pelvic ascites has resolved. No other acute interval changes noted. [fl IMPRESSION: persistent extensive subcutaneous inflammation along bilateral anterolateral abdominal wall, now more fluid filled compared to prev:ious is [sic] seen emphysematous changes. Resolved free intrapelvic fluid. [if] No change in bibasilar atelectasis and dilated proximal small bowel loops, which may represent postoperative ileus or bowel obstruction related to malrotation. Appearance remains unchanged compared to 12-2-17."

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ACCUSATION AND PETITION TO REVOKE PROBATION NO. 800-2019-056493

1 14. On or about December 4, 2017, patient A was admitted to St. Joseph's where he

2 remained until his discharge on or about December 28, 2017. During his hospital stay,

3 Respondent was attended to by several specialists including, but not limited to, general surgery

4 (Dr. S.L.), infectious disease, and intensivists for critical care needs. On December 6, Dr. S.L.

5 performed an emergent exploratory laparotomy for the various preoperative diagnoses which

6 included, but were not limited to, small bowel perforation from outside institution by the plastic

7 surgeon, intestinal subcutaneous fistula, necrotizing fasciitis, septic shock, and status post

8 liposuction from outside facility with iatrogenic small bowel perforation and small bowel

9 obstruction.6 The Operative Report for the emergent surgery noted the following, in pertinent

10 part:

11 "FINDINGS: The patient unfortunately had 3 small bowel enterotomies7 in the mid jejunum. This happened during the iatrogenic injuries that were not found out until

12 today and from outside facility by plastic surgeon. The patient was undergoing a liposuction and liposuction wand penetrated the anterior abdominal fascia, just

13 slightly to the right of the umbilicus and this caused multiple iatrogenic injuries to the small bowel causing enterotomies and 1 large enterotomy was stuck to the ventral

14 hernia or the incisional hernia that was created by the ultrasonic wand from the liposuction causing massive intestinal content spillage into the subcutaneous tissue

15 where all the fat was removed, creating a huge amount ofnecrotizing fasciitis ... "

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(Operative Report dated December 6, 2017.)

In addition to the above, patient A had four additional surgeries on December 8, 15, 19, and

20, 2017, to address problems associated with infection, necrotizing fasciitis and/or abdominal

wounds. Patient A was discharged from St. Joseph's Hospital on December 28, 2017.

15. On or about January 18, 2018, patient A had follow up at St. Joseph's for wound care.

16. On or about January 25, 2018, patient A had follow up at St. Joseph's for wound care.

6 The operative report generally lists the following procedures/operations: (1) emergency exploratory laparotomy; (2) resection of 3 small bowel enterotomies with bowel anastomosis; (3) incidental appendectomy due to malrotation of the gut and wrong location of the appendix; (4) multiple washout of the intra-abdominal cavity; (5) evacuation of the intestinal contents; (6) application of 2 Seprafilms to the pelvis and anterior abdominal contents; (7) excision of the intestinal fistulas, intestinal cutaneous fistulectomy; (8) application of the AmnioFix Allograft 12 x 2 cm in length to the primary anastomotic sites of the small bowel; (9) bilateral flank necrotizing fasciitis, wide excision of the fascia and multiple fasciectomy right a left flanks; (10) deep necrotic tissue biopsy and culture of the left flank area; (11) wound VAC; (12) placement of drains; and (13) midline fascia! defect closure, primary incisional hernia repairs." (Operative Report dated December 6, 2017.)

7 An enterotomy is a surgical incision into an intestine which can be purposeful or the result of an unexpected surgical complication.

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A CCU SA TION AND PETITION TO REVOKE PROBATION NO. 800-2019-056493

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17. On or about February 1, 2018, patient A had follow up at St. Joseph's for wound care.

The "Wound Care Note" for this visit included a "complete disability" assessment which stated,

in pertinent part:

"Complete disability. This complete disability we will give him until May 1, 2018, and then he will not be able to go back to his normal duty for probably the rest of his life. He will have to have minimum weight capability, and then he will need to wear abdominal binder. He will need to be on light duty. From the wound care center and from surgical standpoint, there are no open wounds, and there are no other issues. He just has to start rehab on a very intense way, continue with rehab until May 1st, and then maybe he can go back to work in part-time." (Wound Care Note dated 02-01-18.)

9 18. Respondent committed gross negligence in his care and treatment of patient A which

10 included, but was not limited to, the following:

11 (a) Respondent failed to diagnose abdominal peritonitis with probable bowel

12 perforation and sepsis during his care and treatment of patient A.

13 SECOND CAUSE FOR DISCIPLINE

14 (Repeated Negligent Acts)

15 19. Respondent is further subject to disciplinary action under sections 2227 and 2234, as

16 defined by section 2234, subdivision (c), of the Code, in that Respondent committed repeated

17 negligent acts in his care and treatment of Patient A, as more particularly alleged herein:

18 (a) Paragraphs 9 through 18, above, are hereby incorporated by reference

19 and realleged as if fully set forth herein; .

20 (b) Respondent failed to diagnose abdominal peritonitis with probable

21 bowel perforation and sepsis during his care and treatment of patient A;

22 (c) Respondent failed to maintain and/or produce a complete set for

23 medical records for patient A;

24 ( d) Respondent failed to maintain privileges at any hospital for transfer and

25 care as might be required;

26 ( e) Respondent failed to recognize early signs of intra-abdominal infection

27 during his initial post-operative evaluation of patient A; and

28 1111

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ACCUSATION AND PETITION TO REVOKE PROBATION NO. 800-2019-056493

1 (f) Respondent failed to order x-ray or lab tests during his initial post-

2 operative evaluation of patient A.

3 TIDRD CAUSE FOR DISCIPLINE

4 (Failure to Maintain Adequate and Accurate Records)

5 20. Respondent is further subject to disciplinary action under sections 2227 and 2234, as

6 defined by section 2266, of the Code, in that he has failed to maintain adequate and accurate

7 records in his care and treatment of patient A, as more particularly alleged in paragraphs 9

8 through 18, above, which are incorporated by reference and realleged as if fully set forth herein.

9 FOURTH CAUSE FOR DISCIPLINE

10 (General Unprofessional Misconduct)

11 21. Respondent is further subject to disciplinary action under sections 2227 and 2234 of

12 the Code, in that he has engaged in conduct which breaches the rules or ethical code of the

13 medical profession, or conduct which is unbecoming to a member in good standing of the medical

14 profession, and which demonstrates an unfitness to practice medicine, as more particularly

15 alleged in paragraphs 9 through 20, above, which ~re incorpo~ated by reference and realleged as if

16 fully set forth herein.

17 FIRST CAUSE TO REVOKE PROBATION

18 (Failure to Obey All Laws)

19 22. In a prior disciplinary action entitled In the Matter of the Accusation Against Mark

20 Anthony Knight, MD. before the Medical Board of California, in Case Number 06-2008-190093,

21 Respondent surrendered his medical license effective December 15, 2010, while an Accusation

22 was pending against him for sexual abuse, sexual misconduct and/or sexual relations with patients

23 B.D. and A.D.; gross negligence in the care and treatment of patients B.D. and A.D.; and

24 dishonest or corrupt acts with patients B.D. and A.D. Respondent' subsequently sought

25 reinstatement of his license through a Petition for Reinstatement which was granted on February

26 6, 2015, with an effective date of March 6, 2015. As a result of the Petition for Reinstatement

27 being granted, Respondent's license was reinstated and then immediately revoked, with said

28 revocation being stayed, and Respondent being placed on probation for a period of five years

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ACCUSATION AND PETITION TO REVOKE PROBATION NO. 800-2019-056493

1 from the effective date of March 6, 2015, under various terms and conditions. That decision is

2 now final and is incorporated by reference as if fully set forth herein.

3 23. At all times after the effective date of respondent's probation in Case No. 800-2014-

4 002269, Condition No. 7 of Respondent's probation provided:

5 "7. Obey All Laws [ii] [Respondent] shall obey all federal, state and local

6 laws, all rules governing the practice of medicine in California and remain in full

7 compliance with any court ordered criminal probation, payments, and other orders."

8 - 24. Respondent's probation in Case No. 800-2014-002269 is subject to revocation

9 because he failed to comply with Probation Condition 7, referenced above, in that he has violated

10 rules governing the practice of medicine, as more particularly alleged in paragraphs 9 through 21,

11 above, which are incorporated by reference and realleged as if fully set forth herein.

12 SECOND CAUSE TO REVOKE PROBATION

13 (Violation of Probation)

14 25. At all times after the effective date of respondent's probation in Case No. 800-2014-

15 002269, Condition No. 13 of Respondent's probation provided:

16 "13. Violation of Probation [ii] Failure to fully comply with any term or

17 condition of probation is a violation of probation. If Respondent violates probation

18 in any respect, the Board, after giving Respondent notice and the opportunity to be

19 heard, may revoke probation and carry out the disciplinary order that was stayed. If

20 an Accusation, or Petition to Revoke Probation, or an Interim Suspension Order is

21 filed against Respondent during probation, the Board shall have continuing

22 jurisdiction until the matter is final, and the period of probation shall be extended

23 until the matter is final."

24 26. Respondent's probation in Case No. 800-2014-002269 is subject to revocation

25 because he failed to comply with Probation Condition 13, referenced above, in that he failed to

26 fulfill condition(s) of probation, as alleged in paragraphs 9 through 24, above, which are

27 incorporated by reference as if fully set forth herein.

28 I I I I

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ACCUSATION AND PETITION TO REVOKE PROBATION NO. 800-2019-056493

1 PRAYER

2 WHEREFORE, Complainant requests that a hearing be held on the matters herein alleged,

3 and that following the hearing, the Medical Board of California issue a decision:

4 1. Revoking the probation that was imposed by the Medical Board of California in Case

5 No. 800-2014-002269, effective March 6, 2015, and imposing the disciplinary order that was

6 stayed, thereby revoking Physician's and Surgeon's Certificate Number A78828, issued.to

7 Respondent Mark Anthony Knight, M.D.

8 2. Revoking or suspending Physician's and Surgeon's Certificate Number A78828,

9 issued to Respondent Mark Anthony Knight, M.D.;

10 3. Revoking, suspending or denying approval of Respondent Mark Anthony Knight,

11 M.D.'s authority to supervise physician assistants and advanced practice nurses;

12 4. Ordering Respondent Mark Anthony Knight, M.D., if placed on probation, to pay the

13 Board the costs of probation monitoring; and

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5. Taking such other and further action as deemed necessary and proper.

DATED: August 1, 2019

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ACCUSATION AND PETITION TO REVOKE PROBATION NO. 800-2019-056493